Armature Group complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF as set forth by the U.S. Department of Commerce.  Armature Group has certified to the U.S. Department of Commerce that it adheres to the EU/U.S. DPF Principles with regard to the processing of personal data received from the European Union in reliance on the EU/U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU/U.S. DPF.  If there is any conflict between the terms in this privacy policy and the EU/U.S. DPF Principles, the Principles shall govern.  To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.
 

The Armature Group Privacy Policy outlines the privacy practices that we implement for Personal Data received from the EEA and UK in reliance on the EU/U.S. DPF. The Data Privacy Framework uses the terms defined below:

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• “Personal Data” and “personal information” are data about an identified or identifiable individual that are within the scope of the Directive received by an organization in the
  United States from the EEA or UK and recorded in any form.

• “Processing” of personal data means any operation or set of operations that may be performed on personal data, automated or otherwise—such as collection, recording, organization, storage, adaptation or alteration, retrieval, consultation, use, disclosure or dissemination, and erasure or destruction.

• “Controller” means a person or organization which, alone or jointly with others, determines the purposes and means of processing of personal data.

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Due to the nature of its business, Armature Group is, at times, both the Controller and the Processor of personal information. This Policy describes the information we collect in the normal course of business and from whom. It describes how we use the information as well as how long we retain it. The collection of and processing of personal information of our respondents follows the EU/U.S. DPF and the UK Extension to the EU-U.S. DPF Principles as described in this policy.

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Data Collection

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Types of Data We Collect:

At Armature Group, we collect personal data in order to conduct Market Research on behalf of clients in the pharmaceutical and biotechnology industries. We collect only the personal information required to perform the specific research tasks related to the study or studies that we are conducting.
 

Types of personal data that we may collect include:

• Contact details (name, title, address, email)

• Medical specialty

• Telephone and/or fax numbers

• Certain medical history data as needed

 

At times, special circumstances may require explicit and/or additional consent from our respondents. For example, we obtain explicit consent for video and audio recordings of interviews and focus groups. If adverse events are revealed during the course of data collection, additional consent is requested and the relevant information sent to our client per its own standard protocols.

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Methods of Data Collection

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Armature Group’s methods of collecting data include:

• Online surveys

• Telephone or videoconference (e.g., FocusVisions’s InterVuTM) interviews

• In person interviews, dyads, triads, and focus groups

• Online bulletin boards (OLBBs)

 

Respondents are advised at the time of their initial consent and again at the start of their interview sessions that others affiliated with the research may monitor or view recordings of the data collection process, but that Armature makes efforts to keep their responses anonymous and confidential.

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Purpose of Collecting Personal Data:
Armature Group collects and processes personal information solely for the purposes of executing the primary market research studies it has been commissioned to complete. Our reports and presentations to clients feature aggregated and/or blinded results so that no individual respondent can be associated with his/her opinions. Armature excludes all personally identifiable information (PII) from items shared with its clients and, whenever possible, avoids collecting it altogether.
 

Retention of Information:
We retain personal information only for 90 days after conclusion of its associated study, at which point the information is removed from our systems. The lone exception to this policy is when adverse events are reported during the course of data collection. In this circumstance, we may retain the information for up to 10 years as required by binding agreements with the end client. If no concrete policy exists for retention of adverse event data, Armature will delete it along with any other PII accumulated over the course of the study.
 

Transfer of Data:
In the course of its usual and customary business, Armature Group will occasionally require transfer of data from the EEA, and/or UK. When doing so, it will observe the same degree or greater of protection with regard to personal information.
 

Company Contact:
Anyone concerned about Armature’s use of their personal Information may contact Armature Group via email at info@armaturegroup.net or by telephone at 1-484-413-2024 with any inquiries or complaints. Physical mail may be addressed to Dr. Sally M. Davis, President, Armature Group Inc, 308 East Lancaster Avenue, Suite 215, Wynnewood, PA, 19096.

 

Third Party Service Providers/Suppliers:
The following tasks are routinely performed for Armature by a number of third party service providers:
Transcription, translation, and recruitment of market research participants, preparation of cross-tabs, and statistical analysis and support.
 

Our third party service providers are required to take appropriate security measures to protect personal data that are in line with our security policies.
 

We include standard contractual clauses in our contracts with third party service providers that outline agreed-upon confidentiality and security expectations.

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Respondent Rights

All respondents to the studies that Armature conducts have the following rights with respect to their personal information:

• The right to request access to their information. They are entitled to a copy of the personal information that we hold and to confirm that we are lawfully processing it.

• The right to request a correction to the information that we hold. This allows them to correct any incomplete or incorrect information.

• The right to request erasure of their personal information. They may ask to have it deleted or removed in the event that they no longer want their information processed for the study.

• The right to refuse, restrict, or suspend the processing of their personal information.

• The right to opt out of any recording or additional listeners during an interview.

• The right to invoke binding arbitration under certain conditions.

 

To Process this Request:
There are no fees or other hidden costs for a respondent to request their personal information or to exercise their rights with respect to their information. Armature may request further specific information to help confirm the respondent’s identity to ensure their rights to the specified information in question. Respondents have the right to withdraw their previously provided consent for the specific processing purpose at any time.
 

Accountability and Dispute Resolution:
 

Armature Group is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).

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In compliance with the EU/U.S. DPF Program Principles and the UK Extension to the EU/U.S. DPF, Armature Group, Inc. commits to resolve complaints about our collection or use of your personal information.  EU individuals with inquiries or complaints regarding our Privacy policy should first contact Armature Group, Inc. at: 

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Sally Davis, President: 484-413-2022, sally.davis@armaturegroup.net
 

Judi Schettler, Operations Manager: 484-414-4028, judi.schettler@armaturegroup.net

 

In compliance with the EU/U.S. DPF and the UK Extension to the EU/U.S. DPF, Armature Group, Inc. commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU/U.S. DPF and the UK Extension to the EU/U.S. DPF to INSIGHTS ASSOCIATION DATA PRIVACY FRAMEWORK SERVICES PROGAM, an alternative dispute resolution provider based in the United States.  If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://www.insightsassociation.org/Resources/Data-Privacy-Framework/Information-for-EU-Swiss-Citizens-to-file-a-complaint for more information or to file a complaint.  The services of Insights Association Data Privacy Framework Services Program are provided at no cost to you.

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On its Web site, Armature Group will publish the procedures for verifying compliance and responding to complaints regarding potential deviations from its established procedures for protecting Personal Information.

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Armature Group, Inc. will, under certain circumstances, when permitted or required by law or court order, collect, use and/or disclose Personal information pursuant to procedures that do not require giving notice or conducting related activities (e.g., in connection with law enforcement investigations.

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Armature Group, Inc. maintains its liability in cases of onward transfers to third parties.

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Changes to our Privacy Policy:

We monitor our privacy policy regularly and may update it at any time. You may access our privacy policy at www.armaturegroup.net/privacy-policy